The Centers for Medicare and Medicaid Services (CMS) recently proposed a policy change welcomed by psychologists who provide testing services to Medicare beneficiaries. CMS, the federal agency that administers the Medicare program, is proposing to allow clinical psychologists--defined as any doctoral-level psychologist recognized by Medicare as qualified to provide both therapeutic and diagnostic services--to supervise ancillary staff, such as technicians, who conduct psychological or neuropsychological testing.
Under current federal regulation, a physician must supervise anyone other than a psychologist who performs psychological or neuropsychological tests for Medicare beneficiaries. Expanding the current testing rule has been a priority of the APA Practice Organization, which has sought the rule change for the past two years.
The diagnostic testing policy change is part of an extensive proposed federal rule on the 2005 Medicare fee schedule. In issuing its proposed rule, CMS noted the Practice Organization's rationale in support of the change: The rule's language asserts that psychologists are uniquely qualified to direct test selection and interpret test data based on their knowledge of test measurement and development, psychometric theory, specialized assessment techniques, statistics and human behavior.
Further, the agency noted that the rule change would reduce delays in testing, diagnosis and treatment in rural areas where physicians are unavailable to supervise the tests.
Also, as the Practice Organization advocated, the proposed rule allows psychologists to provide general supervision for psychological and neuropsychological testing at the same level required of physicians supervising the same services. That means that the testing is conducted under the psychologist's overall direction and control, but the psychologist's presence is not required during the testing.
A comment period on the proposed rule ended on Sept. 24, and the agency's decision on whether to finalize the change is anticipated in November, at the same time the 2005 Medicare fee schedule rule is finalized.
The Practice Organization continues to pursue issues related to coding and Medicare payment for diagnostic testing services provided by technicians and other ancillary staff.
--APA PRACTICE ORGANIZATION